Strasbourg, 16 June 2017
MONEYVAL(2017)11
COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM
MONEYVAL
53rd PLENARY MEETING Strasbourg, 30 May – 1 June 2017
MEETING REPORT
MEMORANDUM Prepared by the MONEYVAL Secretariat
Executive Summary
During the 53rd Plenary meeting, held in Strasbourg from 30 May – 1 June 2017, the MONEYVAL Committee:
discussed and adopted the 5th round MER and its executive summary on Slovenia and placed Slovenia in enhanced follow-up; took note of the compliance report of Montenegro under the Compliance Enhancing Procedures, and invited the country to submit a further report at the 54th Plenary (26- 28 September 2017); took note of the follow-up reports by Bulgaria, Lithuania, Poland, and the Slovak Republic under the 4th round of mutual evaluations; applied step 1 of the CEP for the Slovak Republic and invited the country to submit a report at the 55th Plenary took note of an interim report by Romania under the 4th round of mutual evaluations; heard an updated analysis from the Secretariat on the follow-up procedure of the Terrorist Financing Fact-Finding Initiative, and decided to remove from the procedure the following two countries: Lithuania and Poland; heard two presentations on threats and new trends of terrorist financing in light of recent terrorist attacks; heard a presentation on disrupting financial flows associated with slavery, human trafficking, forced labour and child labour; had an exchange of views with experts on the gender-dimension of money laundering; heard presentations on the Council of Europe Convention on the Manipulation of Sport Competitions and the Council of Europe Convention on Offences relating to Cultural Property; adopted the follow-up template for its 5th round of mutual evaluations; discussed a revised Mutual Evaluation Questionnaire on Effectiveness which it subsequently adopted in a “silence procedure“ after the Plenary; discussed changes in its 5th round rules of procedure (to align it with the “universal procedures“ by the FATF) which it subsequently adopted in a “silence procedure“ after the Plenary; hosted within the margins of the Plenary a workshop on the “Egmont Group/World Bank/UNODC-GPML project on FIU cooperation with law enforcement authorities and prosecutors”.
Reports adopted will be made available shortly under each jurisdiction’s profile, in accordance with MONEYVAL’s publication policy.
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The Committee of Experts on the evaluation of anti-money laundering measures and the financing of terrorism (MONEYVAL) held its 53rd Plenary meeting from 30 May – 1 June 2017 in Strasbourg under the chairmanship of Mr Daniel Thelesklaf (Liechtenstein). The agenda of the meeting is attached as Appendix I, MONEYVAL’s calendar of activities is attached as Appendix II, and the list of participants is attached as Appendix III.
Day 1: Tuesday 30 May 2017
Agenda item 1 – Opening of the Plenary Meeting
1. The Chairman, Mr Daniel Thelesklaf, opened the Plenary by welcoming all participants. He asked the Plenary to rise and hold a minute of silence for the victims of the recent terrorist attacks, in Europe and other parts of the world. 2. The Director of Information Society and Action against Crime, Mr Jan Kleijssen, welcomed the agenda items with specific focus on practical implications on combatting terrorist financing. Mr Kleijssen reported about the recent ministerial meeting of the Council of Europe in Cyprus on 19 May 2017. He welcomed the fact that the Czech Republic had been removed from the list of countries by the FATF with gaps in criminalising terrorist financing with regard to the “Terrorist Financing Fact-Finding Initiative”. He also reported from MONEYVAL’s recent high-level mission to Montenegro which took place at the beginning of May. In his capacity as Director for all Council of Europe issues concerning information society, Mr Kleijssen also drew the Plenary’s attention to a recent study1 on the possible misuse of terrorist organisations of virtual currencies, published in May 2017 by the Centre for North American Security. He encouraged the Plenary to address this issue at a future Plenary. Mr Kleijssen also provided an overview to the Plenary of the agenda items related to new Conventions by the Council of Europe which have links with the mandate of MONEYVAL. 3. Mr Kleijssen also reported about the current budgetary planning by the Committee of Ministers for 2018-2019, and updated the Plenary on the staff situation within the MONEYVAL Secretariat. On behalf of the Secretariat, he warmly thanked the delegations of Andorra, Liechtenstein, Malta and Monaco for voluntary contributions which had allowed the recruitment of an administrator for the initial period of two years. This initiative had been started by the Chairman whom he likewise warmly thanked.
Agenda item 2 – Adoption of the agenda
4. The Committee adopted the agenda as circulated (see Appendix I).
Agenda item 3 – Information from the Chairman
5. The Chairman informed the Plenary about the correspondence with MONEYVAL jurisdictions since the 52nd Plenary in December 2016. This included letters he addressed to the Secretary General of the Council of Europe, as well as the Heads of Delegation of FATF members which are Council of Europe member states, concerning the insufficient resource situation in the MONEYVAL Secretariat in light of the expectations of the global AML/CFT-network in the coming years. He also informed about his recent exchange of views with the Committee of Ministers on 10 May 2017, on the occasion of the presentation of MONEYVAL’s annual report 2016, where he had also addressed the above-mentioned resource issue.
1 Centre for North American Security (CNAS), “Terrorist use of virtual currencies – Containing the Potential Threat”, May 2017 (available from the website of the CNAS).
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6. The Chairman also mentioned an information document which Hungary had submitted with regard to its progress made since the last Plenary, which had been circulated as an annex to the Chairman’s correspondence document, and which Hungary would make reference to during its presentation at the tour de table. The Chairman welcomed the additional efforts made by the Hungarian delegation in view of its 5th round follow-up report due at the 55th plenary in December 2017, which displayed the country’s serious commitment in the process.
7. The Chairman further reported about the recent high-level mission by MONEYVAL to Montenegro which took place on 3-4 May 2017, as part of Step 2 of its Compliance Enhancing Procedures. The mission was arranged to meet relevant ministers and senior officials. The MONEYVAL delegation was composed of Mr Daniel Thelesklaf (Chairman of MONEYVAL), Mr Jan Kleijssen (Director of Information Society and Action against Crime) and Mr Matthias Kloth (Executive Secretary to MONEYVAL). The delegation held meetings with the Minister of Foreign Affairs as well as with the Deputy Ministers of Justice and of Finance. This had allowed MONEYVAL to explain at a high political level the urgency of introducing and/or completing certain legislative proposals and to explain the possible consequences for failing to do so. The delegation also held a meeting with representatives from the Montenegrin Parliament to explore ways to accelerate the legislative process in line with the constitutional requirements.
8. The Chairman thanked the Montenegrin delegation for having organised the high-level mission in a very professional and effective manner. The country’s commitment had subsequently been confirmed by a letter of the responsible state secretary in the Ministry of Foreign Affairs which was sent in May to the Chairman and the Executive Secretary (a copy of which was circulated in the chairman’s correspondence file). The letter stated a high-level commitment to swiftly adopt and implement the laws necessary to comply with MONEYVAL’s recommendations from the 2015 MER, and to also enact and implement related regulations. For further information, see the paragraphs of this report under agenda item 5.
Agenda item 4 – Information from the Secretariat
9. The Executive Secretary informed the Plenary about MONEYVAL’s calendar of activities. This included the most recent schedule of evaluations, in particular the onsite visits to Andorra (6 – 18 March 2017) and Ukraine (27 March – 9 April 2017), as well as the dates for the forthcoming onsite visits to Albania (2 – 14 October 2017) and Latvia (30 October – 10 November 2017). Concerning the two-day trainings which countries receive around one year before their onsite visit, he reported about recent workshops in the Czech Republic (March), Lithuania (April) and Moldova (June), with further trainings envisaged for Malta and Cyprus during the second half of the year. A consolidated training for evaluators for the new evaluation round with 50 participants (25 for MONEYVAL and 25 for the FATF) was recently held in Nice from 15-19 May 2017. The Executive Secretary warmly thanked the United Kingdom Crown Dependency of Guernsey for having co- organised and co-sponsored the event, as well as the trainers (Mr John Ringguth, Mr Richard Walker, Mr Yehuda Shaffer and Mr Michael Stellini) for their highly valuable work. MONEYVAL’s calendar of activities is attached to this meeting report as Appendix II.
10. As regards the planned evaluations for 2018, the Executive Secretary informed the Plenary that the Secretariat is planning for four onsite visits, with a fifth one to be conducted should the Secretariat resources be sufficiently increased. The Executive Secretary also informed the Plenary about the most recent situation with regard to staff resources, and strongly encouraged all members to consider making secondees available for the Secretariat.
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11. With regard to Plenary dates, the Executive Secretary recalled that the current Plenary was exceptionally moved to May/June due to changes in the “universal procedures” in 2016, requiring a minimum of 27 weeks between the onsite visit and the discussion of a MER in Plenary. The postponement allowed MONEYVAL to consider at that Plenary the MER of Slovenia, the onsite for which was held in the first half of November 2016. For the Plenary dates for 2017 and 2018, please see agenda item 30 below.
12. The Executive Secretary reported about the FATF Plenary meeting in February 2017, in particular the discussion which took place both in the International Cooperation Review Group (ICRG) and the Plenary on the countries which fulfil the entry criteria for the former during the new evaluation round and the procedure after their observation period has terminated. He also reported about the discussion within the FATF about the fifth year follow-up assessment and its impact on FSRBs such as MONEYVAL.
13. The Executive Secretary further reported about the participation of the MONEYVAL Secretariat in other fora, notably the participation of Mr Andrey Frolov in the FATF joint expert meeting and national risk assessment workshop which was held from 26-29 April in Moscow.
Agenda item 5 – Compliance Enhancing Procedures
5.1 Report from Montenegro under step ii of the Compliance Enhancing Procedures
14. The Secretariat introduced the analysis to the latest compliance report submitted by the Montenegrin delegation. That report has to be seen in conjunction with the latest developments since the high-level mission of MONEYVAL (see above, paragraphs 7-8) to Montenegro (3-4 May), as orally reported by the Montenegrin delegation.
15. According to this oral report, the amendments to the “Law on the Basis of Intelligence and Security Sector” were adopted by the government in March 2017 and by the Parliament in April 2017. Subsequent to MONEYVAL’s high-level mission, the amendments to the criminal code in order to address deficiencies highlighted in the MER, as well as the “Law on Changes and Amendments to the Law on International Restrictive Measures” were adopted by the Government the week before the Plenary and sent to Parliament for adoption, which is expected by the end of June 2017. The “Law on Misdemeanours” as well as the amendments to the “Law on the Prevention of Money Laundering and Terrorist Financing” will be considered by the Government during the month of June 2017 and is likewise expected to be adopted before the summer break by the Parliament. The adoption of the relevant by-laws, rules and procedures will follow the entry into force of these laws. The Montenegrin delegation stressed the importance of the technical assistance and support received by the Council of Europe, and confirmed its commitment to cooperate with MONEYVAL and demonstrate the expected results in the context of the next compliance report for the 54th Plenary in September 2017.
Decision taken
16. The Plenary welcomed both the broad high-level commitment by the Montenegrin government (see paragraphs 7-8), together with the positive and substantial progress made through the recent legislative developments. In the light of these developments, it decided that no further additional steps under the compliance enhancing procedures were considered necessary for the time being. Montenegro was invited by the Plenary to submit an updated compliance report in view of the 54th Plenary in September 2017. Considering in particular whether the above-mentioned legislative proposals are adopted within the indicated timeline by both Government and Parliament by that date, the Plenary will review the situation of Montenegro under MONEYVAL’s compliance
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enhancing procedure and decide under which step the country should then be placed.
Agenda item 6 - ‘Terrorist Financing: threats and new Trends’, presentation by TRACFIN (FIU France) and the French General Directorate for Internal Security
17. The Plenary heard a presentation on threats and emerging trends in terrorist financing, based on feedback from experienced operational units. An overview of the situation in France was provided indicating the approximated number of persons identified as foreign terrorist fighters (FTFs) and amount of money involved. The presentation focused on the typologies most commonly encountered in recent years, in particular regarding the financing of the departure of FTFs and their activities in Syria. Being at a turning point in the war against ISIS, the guest speakers stressed the need for identifying FTFs before their return to their country of origin. They explained how financial investigations could be of crucial importance in this respect. The experts also described new trends and methods in terrorist financing, such as the use of crowd-funding websites for NPOs or collective funds, the use of money remittance offices and money facilitators. Emerging financial threats were also highlighted, such as the use of virtual currencies and mobile banking services which could seriously impair financial transparency.
18. In order to provide comprehensive and useful information to judicial and law enforcement authorities, the major role of internal cooperation between FIUs, intelligence services and cyber security services was emphasised. At the same time, the experts pointed out that international cooperation is a key factor in the identification and localisation of FTFs. Finally, they stated that the future of terrorist assets located in Syria is a matter of acute concern given that they are excluded from traditional financial channels, and therefore can be transferred to other areas in total opacity.
Agenda item 7 - Presentation by Mr Miroslav Kondritsky (senior expert, CFT Department, Rosfinmonitoring): “Responding to the new FT challenges after the latest terrorist attacks”
19. The representative of the Russian Federation FIU (Rosfinmonitoring) gave a short presentation on how Rosfinmonitoring responds to the new FT challenges after the latest terrorist attacks. Rosfinmonitoring has developed a new CFT methodology, taking into account the current characteristics of terrorism such as the changing nature of threats coming from ISIL after its military defeats in Syria and Iraq and the future patrons of FT. Particular attention is also paid to the threat deriving from Foreign Terrorist Fighter returnees (FTFs) and their role in the effort made by international terrorist groups to pile up their presence in Libya, Afghanistan, Yemen and Eastern Africa. In addition, an example of effective co-operation between Rosfinmonitoring and other actors of the national CFT system was presented, which resulted in the prevention of terrorist attacks in Russian cities and the discovery of foreign terrorist co-ordinators in charge of organising ISIL activities (including co-ordination and funding of sleeping terrorist cells) in the Russian Federation and third states.
20. The issue of timely detection and suppression of terrorist activities, conducted by individuals and small terrorist groups at the stage of recruitment and dissemination of radical ideas, was also brought to the attention of MONEYVAL. In this context, the Russian Federation initiated a research project on “financing of recruitment for terrorist purposes” within the framework of the FATF Risks, Trends and Methods Group (RTMG). The project aims to study methods of financial recruitment of various terrorist organisations around the globe; a first draft report will be circulated amongst the FATF Plenary delegations in June 2017.
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Agenda item 8 - FATF Terrorist Financing Fact-Finding Initiative: follow-up procedure within MONEYVAL regarding countries for which significant gaps were identified by the FATF
21. The Secretariat presented its analysis of the third progress update under the dedicated follow-up process within MONEYVAL to the Terrorist Financing Fact-Finding Initiative (TF FFI) undertaken by the FATF to identify jurisdictions in the global network with fundamental or significant gaps in their implementation of FATF Recommendations 5 and 6. The Secretariat described the progress reported by the remaining countries under follow-up to remedy the significant gaps in their legal framework.
22. The Plenary adopted the analysis, and decided to remove Lithuania and Poland from the procedure in light of their progress made. These countries are thus not required to provide any further updates under the TF FFI procedure.
23. In line with the approach taken by the FATF in respect of its own follow-up to the TF FFI, the Plenary decided to give the remaining two countries – Cyprus and “The Former Yugoslav Republic of Macedonia” - additional time until the 54th MONEYVAL Plenary (26-28 September 2017) to enact their planned laws or amendments. Both countries were thus requested to provide a further update to the Secretariat by 1 September 2017 at the latest.
Agenda item 9 – 10: Information on AML/CFT initiatives in MONEYVAL states and territories (tour de table)
24. The Plenary held a tour de table with regard to recent AML/CFT developments in its jurisdictions (for more information on the tour de table see forthcoming document MONEYVAL-Plenary 52(2017)INF9). Delegations which would have been due to report through the biannual update (which was abolished in April 2016 through the streamlining of the 4th round follow-up procedure) and jurisdictions which had fulfilled the ICRG entry criteria in the 5th round of mutual evaluations were given extra time to update the Plenary on recent progress made.
25. The tour de table was conducted at the current Plenary with a particular focus on a presentation by each delegation of a ML or FT case. The Plenary very much welcomed this novelty and decided to hold similar session in the future.
26. During this item, the Chair noted the absence from the Plenary of one delegation without prior notification. The Chair reminded all delegates of the longstanding practice in MONEYVAL that delegations which were unable to attend plenaries would inform in advance the Secretariat in writing.
Agenda items 11 – 12: Information on AML/CFT initiatives in the European Union and other international fora
27. The Plenary heard information about recent initiatives from the European Commission (EC), the European Bank for Reconstruction and Development (EBRD), the Eurasian Group on Combating Money Laundering and Terrorist Financing (EAG), the Financial Action Task Force (FATF), the Group of International Financial Centre Supervisors (GIFCS) and the United Nations Office on Drugs and Crime (UNODC).
28. The representative of the EC provided information on a legislative package issued in December 2016 containing several legislative proposals including: (1) directive on criminalising money laundering; (2) revision of the cash control regulation; (3) proposal for regulation of mutual recognition of freezing and confiscation orders. The first
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establishes minimum rules for the definition of criminal offences and their sanctions. It aims to facilitate cross-border judicial and police cooperation within the EU. In line with the EU’s commitment to accede to the Warsaw Convention, the adoption of this directive will pave the way for the ratification of that Convention by the EU. The second proposal concerns the revision of the EU cash control regulation in accordance with the annex to the FATF standards. The third proposal aims to create a single legal instrument for the recognition of freezing and confiscation orders in other EU countries. It also aims to improve the speed and efficiency of implementation of these orders by setting deadlines. Lastly, the EC representative gave an overview of the on-going revision of the 4th AML directive which is to be transposed in June 2017.
29. The EBRD informed the Plenary that it continues to focus on effectiveness of AML/CFT in its countries of operations through technical assistance. Specifically, the EBRD has conducted seminars designed to educate financial institutions on best practices and the FATF standards.
30. The EAG informed the Plenary of their first on-site visit to Kyrgyzstan as part of the new evaluation round. The representative also shared information on their 26th Plenary (held a week before the MONEYVAL Plenary), the central theme of which concerned TF issues, particularly in relation to ISIS. The EAG Plenary included a joint workshop of the EAG and the CIS anti-terrorism centre. Furthermore, the EAG held a two-day workshop for EAG members on effective AML/CFT supervision as a means of ensuring transparency and stability of financial systems. Lastly, EAG signed a memorandum of understanding with the UN Counter-Terrorism Executive Directorate (CTED).
31. The FATF stated that their main priorities in terms of policy and risk continue to be terrorist financing and beneficial ownership. Multiple on-going projects by the PDG and RTMG reflect these priorities. The mutual evaluation reports of Ireland and Denmark will be discussed at the June Plenary in Valencia, while the FATF Plenary in October/November will take place in Buenos Aires. Lastly, the representative gave an overview of three recent FATF meetings: the Private Sector Consultative Forum, the joint experts meeting in Moscow as well as the FinTech/RegTech Forum.
32. The GIFCS representative updated the Plenary on their recent work on the implementation of the TCSP-standard, including the development of a methodology for assessing compliance with this standard. A key part of this was the development of a multilateral memorandum of understanding to which 14 jurisdictions have committed. Lastly, the representative briefly mentioned the projects that GIFCS is engaged in and contributing to.
33. The UNODC informed the Plenary about the meetings it has hosted and their outcomes, which include: (1) the policy consultative group meeting of the Paris Pact Initiative (PPI), and (2) the meeting of counter-terrorist experts. The representative also mentioned that the UNODC has launched a crypto-currency investigation training course which was delivered for the first time. Lastly, as part of the Commission on Crime Prevention and Criminal Justice (CCPCJ), a side-event on investigation of ML and TF with crypto- currencies took place (a live stream was available on Facebook and Twitter).
34. The first day of the Plenary was concluded with a side event workshop on the “Egmont Group / World Bank / UNODC - GPML project on FIU Cooperation with the LEAs and Prosecutors”, which the former representative of the World Bank to MONEYVAL, Mr Klaudijo Stroligo, had organised. The workshop built upon a presentation on the subject made at the 52nd Plenary in December 2016. The Chairman warmly thanked the organiser for this event which had been attended by a great number of participants and which had generated interesting discussions.
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Day 2: Wednesday 31 May 2017
Agenda item 13 - “Disrupting Financial Flows associated with Slavery, Human Trafficking, Forced Labour and Child Labour”: Presentation by the Chairman, Mr Daniel Thelesklaf
35. The Chairman reported about the attendance of a workshop at the United Nations University in New York in early 2017 on disrupting the financial flows from slavery, human trafficking, forced labour and child labour (which could be featured under the umbrella term “modern slavery”). Stressing the profitability of this sector of organised crime which is estimated by the International Labour Organisation (ILO) to exceed 100 billion US $ per year and concerns an estimated 45 million victims (in particular women and children), he underlined the importance to disrupt the laundering of the proceeds deriving from these predicate offences. Moreover, there are indications that proceeds from the crimes associated with “modern slavery” have also been used to finance terrorist organisations.
36. The Chairman underlined the increasing role of financial sector supervisors and FIUs in detecting financial flows to detect related money laundering activity with regard to “modern slavery”. In some FATF countries, reporting of suspicious activities have increased multiple times in recent years. This in return helped law enforcement authorities to rescue numerous victims of sexual exploitation and human trafficking, and to provide evidence during subsequent criminal trials for human trafficking (thereby reducing the reliance on victim testimony). In this connection, the Chairman also welcomed the recent initiative by the FATF to look into the issue closer within the margins of the RTMG. These efforts have also taken an increased urgency following the adoption of the first UNSCR on human trafficking in December 2016. He also stressed that this topic is one in which MONEYVAL should become more active, given that it can be presumed that human trafficking is an important predicate offence in numerous of its jurisdictions.
37. The Chairman also suggested the strengthening of synergies between MONEYVAL and other Council of Europe bodies. This was very welcomed during delegates’ comments, as well as by the Executive Secretary of the Council of Europe’s Group on Action against Trafficking in Human Beings (GRETA), Ms Petya Nestorova, who was present during the discussion and who made a subsequent short intervention. Ms Nestorova reported on recent workshops for law enforcement authorities in MONEYVAL jurisdictions on financial investigations of human trafficking cases. The expertise of NPOs specialising in human trafficking should also be made use of for any future cooperative work.
Agenda item 14 - Fourth round follow-up: application by Bulgaria to be removed from regular follow-up
38. Following the adoption of the 4th round MER in September 2013, Bulgaria was placed in regular follow-up. Since then Bulgaria has submitted two follow up reports (in September 2015 and September 2016 respectively). Bulgaria was invited to submit a further progress report and seek exit from the regular follow-up process at the 53rd Plenary.
39. The Secretariat analysis of Bulgaria’s third follow-up report concluded at the outset that the country had taken positive steps to remedy shortcomings concerning SR.II. However, despite of additional amendments proposed to the Criminal Code, it appeared that the shortcomings identified under SR.II were not yet fully covered. This primarily concerned the criminalisation of the remaining offences as listed in the Annex to the TF Convention, as well as the abolition of the purposive element of the terrorism/TF offence. At the same
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time, the on-going reform of the Criminal Code also affects the country’s compliance with R.3. Despite of these outstanding issues, the Bulgarian delegation stated that significant efforts were undertaken to bring the country to the level of LC with the remaining core and key recommendations. It also pointed to a recent significant increase in confiscated assets which has an impact on the effectiveness of the country’s confiscation regime.
Decision taken
40. The Plenary took the view that Bulgaria is taking considerable steps forward. However, it found that the country is not yet in a position to exit the regular follow-up procedure. The Plenary also considered that the on-going process of amending the Criminal Code should be awaited, given that further progress is needed in particular with respect to SR.II and R.3. Therefore, the Plenary decided to invite Bulgaria to submit a further progress report and to seek exit from the regular follow-up process at the 55th Plenary in December 2017. Bulgaria was requested to inform Plenary, through the tour de table in September 2017, on the progress with regards to the above-mentioned legislative progress.
Agenda item 15 - Fourth round follow-up: application by Lithuania to be removed from regular follow-up
41. Lithuania’s 4th round mutual evaluation report was adopted in 2012. The country was placed under regular follow-up and compliance enhancing procedures were applied. Since then Lithuania has submitted three compliance reports (in April and September 2014 and in April 2015 when step 1 of the compliance enhancing procedures was lifted) and three follow-up reports (in April 2015 and in April and December 2016 when the country’s request to exit regular follow-up was examined but not granted). Lithuania was therefore invited to submit a further progress report and to seek exit from the regular follow-up process at the 53rd Plenary.
42. The Secretariat analysis of the regular follow-up report concluded that the country had made some progress since the previous follow-up report presented in December 2016, including through an update of the list of indicators to assess possible money laundering or terrorist financing in the NPO sector and by passing amendments to the Criminal Code to explicitly criminalise the financing of a terrorist organisation (in the absence of a link to a specific terrorist act). However, it noted that limited progress had been achieved in relation to R.5 and R.13/SR.IV, given that the new AML/CFT law which should address the deficiencies related to these recommendations has not yet been adopted. It also found that further progress also needed to be achieved in respect of other non-core or key recommendations rated PC in the 4th round MER of Lithuania. The Lithuanian delegation emphasised that the AML/CFT law has been adopted by the Government; it has been submitted to the Parliament for urgent consideration and is foreseen to be adopted in June 2017.
Decision taken
43. The Plenary took the view that Lithuania did not fulfil all the conditions under Rule 13, paragraph 4 for removal from the follow-up process. Although the 5th round on-site visit to Lithuania is envisaged for 2018 and a further application for removal from the 4th round procedure would not be strictly required (as per Rule 13, paragraph 8), the Plenary invited Lithuania to adopt the draft AML/CFT Law as quickly as possible and to subsequently seek removal from the 4th round of mutual evaluations at the 54th Plenary in September 2017.
Agenda item 16 - Fourth round follow up: application by the Slovak Republic to be removed from regular follow-up
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44. The Secretariat presented its analysis on the Slovak Republic’s application to be removed from regular follow-up process under the 4th round follow-up. Since the adoption of the 4th round MER, the Slovak Republic has taken a number of measures with a view to addressing the remaining shortcomings identified in respect of the key and core recommendations. However, there still remain deficiencies related to R.26 and SR.III.
45. At the 52nd Plenary in December 2016, the Plenary considered that the Slovak Republic was not yet in a position to be removed from regular follow-up due to the fact that a number of deficiencies under some key recommendations remain. Therefore, the Plenary invited the Slovak Republic to provide a further follow-up report at the 53rd Plenary and seek then removal from the regular follow-up process.
46. The Slovak Republic has made progress with regard to SR.III, with the new “Act on the implementation of the international sanctions” covering the freezing of assets in the event of control or possession of assets. The deficiencies related to the timely amendment of lists published under UNSCR 1267 have however not yet been addressed. Mechanisms for considering requests for freezing from other countries and procedures for de-listing and unfreezing have been included in the new Act. However, some deficiencies still remain.
47. With regard to Recommendation 26, a proposal for organisational changes related to the position of the FIU within the Police Force was prepared. Despite initial positive feedback from the Presidium of the Police Force, the latter authority’s management refused the request in early 2017. As no formal actions have been taken since the adoption of the 4th round MER, the concerns raised therein relating to the weak formal position of the FIU in the police structure remain. No formal safeguards were introduced to ensure the FIU’s operational independence and autonomy.
Decision taken
48. The Plenary decided to move the Slovak Republic into enhanced follow-up and apply step 1 under the MONEYVAL Compliance Enhancing Procedures. In doing so, the Plenary took into account the severity of the outstanding deficiencies (mostly under R.26 and SR.III) and the fact that the 4th round MER of the Slovak Republic was adopted in September 2011, i.e. more than five and a half years ago. The Slovak Republic was requested to report back to the Plenary on progress made in December 2017.
Agenda item 17 – Fourth round follow-up: application by Poland to be removed from the follow-up
49. Following the 52nd Plenary in December 2016, MONEYVAL had invited Poland to provide another report for consideration at the 53rd Plenary (30 May – 1 June 2017), and urged the country to make progress until this Plenary on addressing the outstanding deficiencies. In line with MONEYVAL’s revised Rules of Procedure, the Plenary recalled that Poland is expected at that occasion to seek removal from the 4th round of mutual evaluation.
50. The 53rd Plenary agreed that, since the adoption of the 4th round MER in 2013, Poland had made clear progress in addressing many of the deficiencies identified in the previous evaluation, notably in respect of R.1, R.3, R.35, SR.I and SR.II. Nevertheless, the draft AML/CFT Law which is expected to address the outstanding deficiencies in relation to preventive measures (R.5, R.13 and SR.IV), as well as the deficiencies in relation to targeted financial sanctions (SR.III), is yet to be adopted by the Parliament which is envisaged for June 2017.
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Decision taken
51. Given the progress made by Poland under SR.II and other key and core recommendations, and taking into account the fact that the AML/CFT draft law is expected to be adopted very shortly, the Plenary agreed to grant Poland some extra time for finalising the adoption of the AML/CFT law and to decide on its application to be removed from the regular follow-up process at the next Plenary in September 2017. Should the draft AML/CFT not yet be in force by the time of the next Plenary in September, the Plenary will - in accordance with Rule 13, paragraph 6 of its Rules of Procedure - consider the application of Compliance Enhancing Procedures (CEPs).
Agenda item 18 – Fourth round follow-up: interim follow-up report by Romania
52. Romania’s 4th round MER was adopted in April 2014. Two years later, in April 2016, the country presented a first interim report under the regular follow-up process. The Secretariat noted that, although a number of legislative remedial actions had been prepared, limited concrete progress had been achieved. Romania was asked then to report back at the present Plenary and was encouraged to apply for removal from follow- up on that occasion.
53. At the present Plenary, the Secretariat noted that three key legislative processes were still underway: amendments to the AML/CFT Law aimed at addressing major deficiencies under R.26; a new AML/CFT intended to transpose the 4th EU AML Directive into national legislation; and amendments to the Emergency Ordinance on the implementation of international sanctions. Since none of those draft pieces of legislation were in force by the time it prepared its analysis, the Secretariat was not in a position to conduct a detailed evaluation of progress reported by Romania. However, it noted that the envisaged changes could address a number of significant gaps identified under the core and key Recommendations in the MER. During the Plenary meeting, Romania informed the Secretariat that the amendments to the AML/CFT law had been promulgated by the President of the Republic on 31 May.
Decision taken
54. Considering the expected timeframe for the adoption of the other two pieces of legislation (i.e. by the end July regarding the new AML/CFT law; by end of year regarding the amendments to the Emergency Ordinance), the Plenary asked Romania to report back at the 56th Plenary in April 2018, with a view to applying for exit from follow-up on that occasion. This would be in line with the four-year deadline for exit from follow-up set by the revised Rule 13 of MONEYVAL’s 4th round rules of procedure.
Agenda item 19 - Overview of MONEYVAL’s follow-up process in its 5th round of evaluations and adoption of the follow-up template
55. The Secretariat provided an overview of the follow-up procedure for the 5th round of mutual evaluations which will commence at the 54th Plenary (September 2017). It explained the role of rapporteur teams, the process leading to the analysis of the follow- up report, and the deadlines involved as well as the coordinating role of the Secretariat. For the appointment of the rapporteur teams, see agenda item 21 below.
56. The Plenary discussed and subsequently adopted the new template for follow-up reports, which is as far as possible aligned with the template for the ICRG process, to avoid duplicity in the work with regard to those countries which fulfil the ICRG-entry criteria.
Agenda item 20 - Proposal for a revised Mutual Evaluation Questionnaire of
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Effectiveness
57. The Secretariat put forward a proposal for a revised Mutual Evaluation Questionnaire on Effectiveness. It explained that the revisions were carried out to shift the focus of the questionnaire from the examples of information and specific factors that could support the conclusions on core issues in the FATF Methodology to the core issues themselves. The specific factors and examples of information were maintained. However, they were integrated under the different core issues. Instructions on how to complete the questionnaire were inserted at the top of the document. The Questionnaire on Technical Compliance and the template of statistics were not amended, except for a few minor changes to some of the statistics tables. It was proposed that the countries whose evaluation was scheduled for 2018 would provide feedback on the quality of the questionnaire.
58. The Plenary adopted the questionnaire subject to any written comments received from the delegations. All delegations were invited to provide comments in writing within one week after the end of the Plenary. Should no comments of a substantial nature be received, the Plenary would adopt the questionnaire in a “silence procedure”. By the end of that deadline, the Secretariat had received comments from one delegation which were integrated but not of a substantial nature.
Agenda item 21 - Appointment of the Rapporteur Team for the follow-up reports to be considered at the 54th and 55th Plenaries (Rule 21, paragraph 6 of MONEYVAL’s 5th round Rules of Procedure as well as Rules 39 and 41 of MONEYVAL’s 3rd round Rules of Procedure)
59. The Plenary appointed Bulgaria and Croatia as rapporteur teams for the 5th round follow- up report of Serbia which will be considered at MONEYVAL’s 54th Plenary in September. Concerning the 5th round follow-up report of Hungary which will be considered at MONEYVAL’s 55th Plenary in December, the Plenary appointed Armenia and the UK Crown Dependency of Jersey as rapporteur teams. San Marino was appointed as rapporteur country for the 3rd round follow-up report of the Holy See which will be discussed at MONEYVAL’s 55th Plenary in December.
Agenda item 22 - Amendment of MONEYVAL’s 5th round Rules of Procedure in light of recent changes in the Universal Procedures
60. The Secretariat introduced a paper with a few amendments to MONEYVAL’s 5th round rules of procedure, in order to align it with recent changes to the “universal procedures” by the FATF. These were on the one hand related to the situation that a country has significantly lowered its compliance with the FATF standards after the adoption of a mutual evaluation report; the changes give the Plenary the possibility to request the country to address these new deficiencies as part of the follow-up process, and to place a country from regular to enhanced follow-up if the criteria for the latter are retrospectively fulfilled because of these changes. An additional change concerned the relationship of the follow-up process with the ICRG process for those countries which may be placed in that process, in order to avoid duplicity in both procedures. The Plenary decided to give delegation two weeks to comment on the proposed changes to the 5th round rules of procedures. As no objection from any delegation was received by that deadline, the proposed changes were adopted in a “silence procedure”. The updated version of the rules of procedure has subsequently been made available on the MONEYVAL website.
61. The Plenary also considered a proposal from the Bureau to suggest to the Committee of Ministers an amendment to the MONEYAL Statute in order to have an additional Vice- Chair. The proposal is based on the need for MONEYVAL to be increasingly represented
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outside of the Council of Europe in a large number of AML/CFT platforms (e.g. the FATF and its five working groups, as well as the ERRG). In order to ensure high-level representation, a second Vice-Chair was considered feasible by the Bureau, which is the practice in most of the monitoring bodies of the Council of Europe. While the number of Bureau members would remain unchanged, the envisaged proposal would require changes in MONEYVAL’s Statute, and subsequently its rules of procedure. The Plenary accepted the proposal and instructed the MONEYVAL Secretariat to forward the request to the Secretariat of the Committee of Ministers for consideration. If the request would be treated favourably by the Committee of Ministers, the Plenary decided that it would amend its rules of procedure in September and hold Bureau elections under the new rules in December.
Agenda item 23 - “Gender and money laundering: insights from research and implications for practice”: presentation by and exchange of views with Prof. Wim Huisman and Dr. Anne-Marie Slotboom, Department of Criminal law and Criminology, VU University Amsterdam
62. The Plenary held an exchange of views with two academic experts (Professor Wim Huisman and Dr. Anne-Marie Slotboom of the VU University Amsterdam) on the gender dimension of money laundering. MONEYVAL’s Gender Equality Rapporteur, Ms Maja Cvetkovski, introduced the agenda item and the academic experts. She described various recent initiatives by other Council of Europe committees to explore the gender dimensions in (action against) crime, and underlined the importance of raising awareness and exchanging views on the issue in the MONEYVAL committee as an initial step towards exploring the need for further activities.
63. The Plenary heard a presentation from the two academic experts with a focus on women as offenders. Dr. Slotboom started with a general presentation on theories and research into gender and crime, outlining concepts such as the gender similarity hypothesis, the gender-crime ratio and gender bias. Professor Huisman focused on research into the shares and roles of women in white collar crime and organised crime, including in the money laundering process. This included studies of the presumed positive effect of gender diversity on corporate boards on regulatory compliance, as well as on the organisational roles of women in organised crime groups. Research so far indicates that, while women are the minority with respect to money laundering, this minority is a sizeable one (around 20%) with mostly supportive roles in the laundering process.
64. Two opposing hypotheses were presented to explain the lower ratio of women in white collar crime. According to the “vulnerability hypothesis”, women are less inclined to take risky behaviour; thus more women in leading positions would be expected to lead to less white collar crime in general. The “exposure hypothesis”, on the other hand, holds that the reasons for the gender gap mostly have to do with access and possibilities to commit crime, and not with psychological differences between men and women; therefore, one can expect more female white-collar crime with advancing emancipation. However, the academics noted that more good-quality empirical research is needed to shed light on the value of these hypotheses.
65. Various delegations commented that they recognised to some extent the patterns and roles highlighted in the presentation. Mr. Gianluca Esposito, Executive Secretary of the Council of Europe Group against Corruption (GRECO), stated that GRECO wants to look further into the underlying causes for the gender gap that has been found to exist in corruption so far; he was looking forward to potential cooperation with MONEYVAL in this respect to explore the gender dimensions of economic crime. The Gender Equality Rapporteur invited delegations to express their interest for participation in further work on the gender dimension of money laundering.
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Agenda item 24 - European Convention on Offences relating to Cultural Property: presentation on the money laundering and terrorist financing aspects of the Convention by Mr Carlo Chiaromonte, Secretary to CODEXTER and Head of the Criminal Law Division, Department of Action against Crime
66. The Plenary heard a presentation by Mr Chiaromonte on the European Convention on Offences relating to Cultural Property. He informed the Plenary of the adoption of this new Convention in May 2017, and its signature by so far six countries. This Convention aims to prevent and combat the illicit trafficking and destruction of cultural property, in the framework of the Council of Europe’s action to fight terrorism and organised crime.
67. Mr Chiaromonte recalled the origins of the convention and the factors that led to its creation, in particular the general awareness that had arisen after the taking of the city of Palmyra by ISIS. He also stressed that the Convention was built on instruments relating to cultural property, such as the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, in order to make sure that the Convention is fully compatible with relevant existing international legally binding standards. The new Convention will be the only international treaty specifically dealing with the criminalisation of the illicit trafficking of cultural property. It is aimed at enhancing law enforcement capacity by requiring State Parties to implement several important provisions concerning cultural property into their criminal law, as well as further ensuring the ability to investigate, prosecute, sentence and/or extradite persons suspected or convicted of offences falling under the ambit of the Convention.
Agenda item 25 - The new Council of Europe Convention on the Manipulation of Sport Competitions and its money laundering aspects: presentation by Mikhaël de Thyse / Cassandra Fernandez (Directorate-General II – Unit for Sport Conventions)
68. The representatives of the Council of Europe Sport Conventions Division gave a short presentation of the Council of Europe Convention on the Manipulation of Sports Competitions and the nexus between sports and crime. This new Convention was adopted in 2014, but has not yet reached the five ratifications needed to enter into force. It provides for instruments and tools in order to tackle emerging threats deriving from the involvement of organised crime in the manipulation of sports competitions. The lack of legal measures to criminalise the manipulation of sports competitions in most countries minimises the risk for those who invest in such activities. Moreover, the large number of stakeholders involved in the prevention, detection and sanctioning of match fixing entails difficulties in the level of co-operation and co-ordination. To this end, the Convention provides both for sanctions and measures against natural and legal persons, and identification of a national platform to facilitate the co-ordination and co-operation among all stakeholders at national and international level.
69. Concrete examples of the exploitation of betting market at large by criminals were brought to the Committee’s attention. The low regulation of sport competitions makes them vulnerable to criminals who launder their profits from trafficking in human beings, drugs trafficking or other predicate offences for ML. Legal betting can be used for ML, due to the low priority and regulation of the betting markets. Moreover, sport associations, federations and clubs are used as cells for ML through players’ transfers and sponsoring activities. In this context, the importance was stressed of tracking and confiscation of criminal profits, as a method for preventing the continuation of organised crime groups’ efforts to commit criminal offences relating to the manipulation of sports competitions. The significance of the 2013 MONEYVAL “Online Gambling” typologies research, and the need to update it in order to include all types of possible manipulations, were outlined as well as the exploration of a common field for future co-operation with MONEYVAL.
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Day 3: Thursday 1 June 2017
Agenda items 26 and 27 – Discussion of the draft 5th round Mutual Evaluation Report on Slovenia
70. The Chairman introduced the draft Mutual Evaluation Report (MER) of Slovenia. He thanked all delegations which had submitted written comments on the MER which served as a basis for selecting the key issues that were discussed in the Working Group on Evaluations (WGE). He also thanked the Co-Chair of the WGE, Nicola Muccioli, for his valuable contributions in the finalising the evaluation process. The Secretariat introduced the evaluation team and provided an overview of the key findings and priority actions set out at the beginning of the draft MER. Moreover, it explained the structure of the “revised key issues”-document.
71. The Co-Chair of the WGE summarised the discussion and decisions taken by the WGE on each key issue. He then explained the information provided under Annex 1 to the “revised key issues”-document. Furthermore, he provided a short overview of key issues which no longer needed to be discussed in the Plenary. In particular, further to comments submitted by the Scientific Expert Mr John Ringguth and the FATF, the WGE agreed that IO2 would be amended to include additional MLA case examples. There was agreement that additions to the language of and conclusions for this immediate outcome would better support the current rating, which in return did no longer require a further discussion of this key issue (i.e. key issue 2) by the Plenary.
Key issue 1 – Immediate Outcome 1
72. Regarding requests for specification: The Co-Chair of the WGE introduced various requests for specification of some of the key findings and recommended actions of IO.1, as put forward by delegations and discussed during the WGE. These related to the participation of the private sector in the NRA; risks related to cross-border cash transactions and NPOs; exemptions/simplified/enhanced measures; cooperation and coordination; and internal risk assessments by obliged entities. The evaluation team emphasised that it was of the opinion that the key findings and recommendations in their current form adequately captured these elements. It was recalled that key findings and recommended actions should be consistent , but do not need to exactly mirror each other. Furthermore, key findings and recommended actions should be read in conjunction with the text of the analysis. If the key findings and recommended actions were to be further specified rather than framed in more comprehensive terms, they would no longer capture all the issues within their scope as described in the analysis. There was no consensus in the Plenary to change the language of the key findings and recommended actions. The Chair thanked the delegations for putting forward these suggestions, which even when not accepted were very useful to serve as guidance for future work.
73. Regarding the TF risk assessment: The Co-Chair of the WGE summarised the discussion of the WGE on the concerns expressed by various delegations on the limited TF risk assessment, and the arguments provided by the evaluation team that the TF risk understanding among key authorities was found to go beyond the limited analysis of the NRA. The Plenary was satisfied by the explanations given. Hence there was no request for further discussion.
74. Regarding the rating: The Co-Chair of the WGE reported that there were requests for both upgrading and downgrading of the current rating of “moderate”. The request for
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upgrading related to concerns for inconsistency with the MER of the Isle of Man which received a rating of “substantial”. The evaluation team explained the reasons for not deeming appropriate a rating of “substantial” for the present MER, and for distinguishing between the two jurisdictions concerned regarding risk and context. This view was supported by a number of delegations. The evaluation team further explained its reasons for determining the rating of “moderate”, as it had balanced both the positive and negative features of the whole chain of risk assessment, understanding and mitigation by the Slovenian authorities. Following the discussion, there was no consensus in the Plenary to change the rating either way.
Key Issue 3 – Immediate Outcome 3
75. The Co-Chair of the WGE reported on the discussion that took place in the WGE as to whether fundamental rather than major improvements are needed in the Slovenian supervisory system. Italy recalled their preference for downgrading the rating and their concerns regarding the lack of coordination between supervisors, the lack of exchange of information between LEAs and the Bank of Slovenia regarding the checking of criminal background of people seeking to own or control banks, as well as the lack of understanding of TF risks by FI supervisors. Italy also referred to the technical deficiency under R.26 regarding the absence of the technical requirement to periodically review the risk assessment profiles.
76. The Slovenia authorities gave explanations on those issues and confirmed that, despite of the possible technical gap, the Bank of Slovenia does periodical reviews of risk profiles. The Slovenia authorities also explained that there is cooperation between the LEAs and the Bank of Slovenia, albeit this cooperation could be enhanced. The assessment team explained that, in their opinion, the rating was appropriate and that strong weighting was given to the FI supervisors’ efforts, especially the Bank of Slovenia which had a good understanding of ML risks and has conducted risk-based supervision. Whilst acknowledging that major improvements are still needed, these improvements should not be categorised as “fundamental”.
77. As there was no consensus to downgrade the rating for the IO.3, the Plenary decided that the rating of “moderate effectiveness” would remain.
Key issue 4 – Immediate Outcome 8
78. The Co-Chair of the WGE summarised the discussion that took place in the WGE on IO.8. The Plenary then discussed whether the current analysis of IO.8 supports a “low” or “moderate” effectiveness rating. The Slovenian delegation provided additional explanations on their confiscation regime, in particular concerning successful confiscation cases involving significant amounts as well as recent constitutional court decisions confirming the constitutionality of the civil confiscation regime. These explanations justified, in the view of the Slovenian delegation, an upgrade from “low” to “moderate”. The delegations of the UK Crown Dependencies of Guernsey and Jersey, the Czech Republic, the “Former Yugoslav Republic of Macedonia“ and Montenegro argued that the features of the Slovenian confiscation regime would justify a “moderate” rating. In particular, the introduction of the possibility of civil confiscation indicated the country’s commitment to pursue criminal assets and to put in place the effective confiscation system. Given the large support the Plenary decided to upgrade the rating for IO.8 from “low” to “moderate”. Certain modifications in the language of the analysis under IO.8 were suggested, and the evaluation team will consider them when making the relevant amendments to the text of MER.
Key Issue 5 – Immediate Outcome 9
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79. The Co-Chair of the WGE reported on the discussion that took place in the WGE as to whether fundamental rather than major improvements are needed in the Slovenian CFT system, as well as on the need for clarification of the required level of proof for terrorist offences.
80. Various delegations argued that, having regard to the proposed amendment to paragraph 271, that paragraph still caused confusion on the issue of the level of proof (and the appropriateness of the cited case as an illustration of this issue). Slovenia confirmed that the level of proof for convictions (the civil law standard of the court being “convinced” by the evidence) is the same as for all criminal offences. The evaluation team explained how it arrived nonetheless at the finding that there was a perception among practitioners that evidentiary thresholds for the terrorist and TF offences are particularly high, which may potentially impact on decisions in the pre-investigative stage. It was however emphasised that this is an assumption, which should not receive too much weight in the rating. Based on the discussion, the evaluation team agreed to carefully reconsider the wording of paragraph 271.
81. The Plenary agreed with the proposed changes to paragraph 288 to better reflect the weight given to the lack of TF risk communication to the private sector and the lack of a national CTF strategy. Delegations expressed support for the current rating, citing the evidence for various positive aspects of the system and having regard to the approach taken in previous reports towards the evaluation of effectiveness in the absence of prosecutions. There were no more requests for downgrading, and there was clear consensus that the rating should stay “moderate”.
Additional issues raised – Immediate Outcome 6
82. Italy asked for a clarification regarding the independence of the Slovenian FIU. It also asked to remove from the MER any references to the neighbouring countries when referring to a certain typology. The assessment team agreed to replace such references throughout the report with a neutral reference. The FATF asked to move information under paragraph 170 to another part of either IO.6 or IO.7, which the assessment team accepted.
Decision taken
83. The Plenary adopted the 5th round MER of the Slovenia and its executive summary, including the amendments agreed upon during the discussion and subject to further editorial changes. According to Rules 21 and 23 of MONEYVAL’s 5th Round Rules of Procedure, Slovenia was placed in enhanced follow-up and requested to report back four Plenaries from the present Plenary, i.e. in September 2018.
Agenda item 28 – Presentation by the Secretariat of the new MONEYVAL public and restricted websites
84. This agenda item was postponed to the 54th Plenary in September due to the absence for personal reasons of the person assigned to the presentation.
Agenda item 29 – Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (CETS No. 198)
85. The Secretariat informed the Plenary about recent ratifications of the Convention, notably
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by Italy (February), as well as about the forthcoming Bureau meeting in June.
Agenda item 30 – Miscellaneous
86. MONEYVAL will hold its 54th Plenary from 26-28 September 2017 and its 55th Plenary from 6-8 December 2017.
87. As regards the tentative dates for the Plenaries in 2018, the Secretariat announced that MONEYVAL will hold its 56th Plenary from 24-26 April 2018, its 57th Plenary from 18-21 September 2017, and its 58th Plenary from 4-7 December 2018. As previously, the day before the first day of each Plenary will be reserved for the meetings of the Working Group on Evaluations (WGE). Depending on whether one or two 5th round mutual evaluation reports will be discussed at these Plenaries, it is possible that the 57th and the 58th Plenaries may be shortened by one day. The Secretariat will confirm this in due time.
APPENDIX I
Agenda of the Plenary
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Day 1: Tuesday 30 May 2017 / 1er jour: mardi 30 mai 2017
Morning 9.30 a.m. / matin 9h30
1. Opening of the Plenary Meeting at 9.30 a.m. / Ouverture de la réunion plénière à 9h30 1.1 Statement by Mr Jan Kleijssen, Director, Directorate Information Society and Action against Crime / Allocution de M. Jan Kleijssen, Directeur de la Direction de la société de l’information et de la lutte contre la criminalité
2. Adoption of the Agenda / Adoption de l’ordre du jour
3. Information from the Chairman / Informations communiquées par le Président 3.1 Chairman’s correspondence / Correspondance du Président
3.2 Chairman’s report of the high-level mission to Montenegro (Step 2 CEPs) on 3-4 May 2017 / Rapport du Président sur la mission de haut niveau au Monténégro (PCR étape 2) des 3 et 4 mai 2017
4. Information from the Secretariat / Informations communiquées par le Secrétariat 4.1 MONEYVAL calendar of activities 2017 / Calendrier des activités en 2017
4.2 Report from the Secretariat on the February FATF meeting / Rapport du Secrétariat sur la réunion de février du GAFI
4.3 Reports on Secretariat attendance in other fora / Rapports du Secrétariat sur sa participation aux réunions d’autres institutions
4.4 Planning for the upcoming evaluations / Planning des évaluations à venir
4.5 Financing and staffing / Financement et questions de personnel
4.6 Future representation in FATF meetings / Représentations futures dans les réunions du GAFI
5. Compliance Enhancing Procedures / Procédures de conformité renforcée 5.1 Report from Montenegro under step II of the Compliance Enhancing Procedures / Rapport du Montenegro au titre de l’étape (ii) des Procédures de conformité renforcée
6. “Terrorist Financing: threats and new Trends”, presentation by Mr Arnaud BALESTE, Head of CFT Division, TRACFIN and Mr Xavier BAYLON, General Directorate for Internal Security/ “Financement terroriste: menaces et nouvelles tendances”, présentation de MM. Arnaud Baleste, Chef de la division CFT, TRACFIN, et Xavier Baylon, Directeur Général pour la sécurité intérieure
7. “Responding to the new FT challenges after the latest terrorist attacks”, presentation by Mr Miroslav Kondritsky (senior expert, CFT Department, Rosfinmonitoring) / “Faire face aux nouveaux challenges en matière de financement du terrorisme suite aux dernières attaques terroristes”, présentation de M. Miroslav Kondritsky (expert principal, Département CFT, Rosfinmonitoring)
8. FATF Terrorist Financing Fact-Finding Initiative: follow-up procedure within MONEYVAL regarding countries for which significant gaps were identified by the FATF / Initiative du GAFI sur la question terroriste: procédure de suivi au sein de MONEYVAL sur les pays pour lesquels le GAFI a identifié de sérieux manquements
9. Information on AML/CFT initiatives in MONEYVAL States and territories (tour de table) / Informations sur les initiatives LAB/CFT des Etats et territoires de MONEYVAL (tour de table)
Afternoon 2.30 p.m. / après-midi 14h30
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10. Information on AML/CFT initiatives in MONEYVAL States and territories (tour de table, continued) / Informations sur les initiatives LAB/CFT des Etats et territoires de MONEYVAL (tour de table, suite)
11. Information from the European Union / Information de l’Union européenne
11.1 European Commission / Commission européenne 11.2 Secretariat General / Secrétariat Général
12. Information on AML/CFT initiatives in other fora / Informations sur les initiatives LAB/CFT d’autres institutions
12.1 Council of Europe Development Bank / Banque de Développement du Conseil de l’Europe 12.2 EBRD / BERD 12.3 Egmont Group / Groupe Egmont 12.4 Eurasian Group on Combating Money Laundering and Terrorist Financing (EAG) / Groupe Eurasie sur le blanchiment d’argent et le financement du terrorisme (EAG) 12.5 FATF / GAFI 12.6 GIFCS / GSCFI 12.7 IMF / FMI 12.8 OSCE 12.9 UNODC / ONUDC 12.10 World Bank / Banque Mondiale
Side event (5.30 p.m. – 7.30 p.m. in the same room, without translation): Workshop on the “Egmont Group / World Bank / UNODC - GPML project on FIU Cooperation with the LEAs and Prosecutors” / Evénement parallèle (17h30-19h30, dans la même salle, sans interprétation): Session sur un projet joint “Groupe Egmont/Banque mondiale/UNODC-GPML sur la coopération des CRF avec les autorités policières et les procureurs”
Day 2: Wednesday 31 May / 2ème jour: mercredi 31 mai
Morning 9.30 a.m. / matin 9h30
13. “Disrupting Financial Flows associated with Slavery, Human Trafficking, Forced Labour and Child Labour”: Presentation by the Chairman, Mr Daniel Thelesklaf / “Perturber les flux de capitaux en lien avec l’esclavage, la traite des humains, le travail forcé et le travail des enfants” : présentation du Président, M. Daniel Thelesklaf
14. Fourth round follow-up: application by Bulgaria to be removed from regular follow-up / Suivi au titre du quatrième cycle: demande de la Bulgarie de sortir de la procédure de suivi régulier
15. Fourth round follow-up: application by Lithuania to be removed from regular follow-up / Suivi au titre du quatrième cycle: demande de la Lituanie de sortir de la procédure de suivi régulier
16. Fourth round follow-up: application by the Slovak Republic to be removed from regular follow-up / Suivi au titre du quatrième cycle: demande de la République slovaque de sortir de la procédure de suivi régulier
17. Fourth round follow-up: application by Poland to be removed from regular follow-up / Suivi
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au titre du quatrième cycle: demande de la Pologne de sortir de la procédure de suivi régulier
18. Fourth round follow-up: interim follow-up report by Romania / Suivi au titre du quatrième cycle: rapport de suivi intermédiaire de la Roumanie
Afternoon 2.30 p.m. / après-midi 14h30
19. Overview of MONEYVAL’s follow-up process in its 5th round of evaluations and adoption of the follow up template / Résumé des procédures de suivi de MONEYVAL au titre du 5ème cycle d’évaluations et adoption du modèle de rapport
20. Proposal for a revised Mutual Evaluation Questionnaire of Effectiveness / Proposition d’un questionnaire d’évaluation mutuelle révisé sur l’efficacité
21. Appointment of the Rapporteur Team for the follow-up reports to be considered at the 54th and 55th Plenaries (Rule 21, paragraph 6 of MONEYVAL’s 5th round Rules of Procedure as well as Rules 39 and 41 of MONEYVAL’s 3rd round Rules of Procedure) / Nomination de l’équipe de rapporteurs pour les rapports de suivi qui seront examinés lors des 54ème et 55ème sessions plénières (Règle 21, paragraphe 6 des Règles de procédure du 5ème cycle de MONEYVAL et Règles 39 et 41 des Règles de procédure du 3ème cycle)
22. Amendment of MONEYVAL’s 5th round Rules of Procedure in light of recent changes in the Universal Procedures / Modifications des Règles de procédure de MONEYVAL du 5ème cycle suite aux récents changements dans les Procédures universelles
23. “Gender and money laundering: insights from research and implications for practice”: presentation by and exchange of views with Prof. Willem Huisman and Prof. Maria Slotboom, Department of Criminal law and Criminology, VU University of Amsterdam / “Sexe et blanchiment d’argent : résultats de recherches et implications dans la pratique”: présentation suivi d’un échange de vues avec les professeurs Willem Huisman et Maria Slotboom, du Département de droit pénal et de criminologie de l’université VU d’Amsterdam
24. European Convention on Offences relating to Cultural Property: presentation on the money laundering and terrorist financing aspects of the Convention by Carlo Chiaromonte, Secretary to CODEXTER and Head of the Criminal Law Division, Department of Action against Crime / Convention européenne sur les infractions visant des biens culturels : présentation sur les aspects liés au blanchiment d’argent et au financement du terrorisme de la Convention par Carlo Chiaromonte, Secrétaire du CODEXTER et Chef de la division du Droit pénal, Département de l’action contre le crime
25. The new Council of Europe Convention on the Manipulation of Sport Competitions and its money laundering aspects: presentation by Mikhaël de Thyse / Cassandra Fernandez (Directorate-General II – Unit for Sport Conventions) / La nouvelle Convention du Conseil de l’Europe sur la manipulation de compétitions sportives et ses aspects liés au blanchiment d’argent : présentation de Mikhaël de Thyse et Cassandra Fernandez (Direction générale II – Conventions du sport)
Day 3: Thursday 1 June / 3ème jour: jeudi 1 juin
Morning 9.30 a.m. / matin 9h30
26. Discussion on the draft 5th round Mutual Evaluation Report on Slovenia / Discussion du
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projet de rapport d’évaluation mutuelle du 5e cycle de la Slovénie
Afternoon 2.30 p.m. / après-midi 14h30
27. Continuation of the discussion on the draft 5th round Mutual Evaluation Report on Slovenia / Suite de la discussion du projet de rapport d’évaluation mutuelle du 5e cycle de la Slovénie
28. Presentation by the Secretariat of the new MONEYVAL public and restricted websites / Présentation du Secrétariat des nouveaux sites web publics et restreints de MONEYVAL
29. Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (CETS No. 198) / Convention du Conseil de l’Europe relative au blanchiment, au dépistage, à la saisie et à la confiscation des produits du crime et au financement du terrorisme (STCE No. 198)
30. Miscellaneous / Divers
APPENDIX II
Calendar of activities (June 2017 – May 2018)
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2017 (June-December)
12-13 June Country Training Moldova
18-23 June FATF Plenary, Spain (Valencia)
28 June COP Bureau meeting
Pre-meeting with evaluators 6-7 July Ukraine
19-21 July Face-to-Face meeting Andorra
25 September Working Group on Evaluations 5th round MER: Andorra
26-28 September PLEN 54 5th round follow-up: Serbia
September (tbc) Country Training Malta
Face-to-face meeting 2-4 October (tbc) Ukraine
2-14 October 5th round onsite visit to Albania
October (tbc) Country Training Cyprus
FATF Plenary, Buenos Aires 29 October – 3 November (Argentina)
30 October – 10 5th round onsite visit to Latvia November
21-22 November COP Plenary + Bureau
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4 December Working Group on Evaluations 5th round MER: Ukraine
5th round follow-up: Hungary 5-7 December PLEN 55
2018 (January- May)
5th round onsite visit to the Czech 5-16 March Republic
23 April Working Group on Evaluations 5th round MER: Albania
5th round follow-up: Isle of Man 24-26 April PLEN 56
7-19 May 5th round onsite visit to Lithuania
5th round MONEYVAL evaluators May (tbc) training
APPENDIX III
List of participants
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Strasbourg, 29/05/2017 MONEYVAL53(2017)LIST Restricted / Restreint
COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM /
COMITÉ D’EXPERTS SUR L’ÉVALUATION DES MESURES DE LUTTE CONTRE LE BLANCHIMENT DES CAPITAUX ET LE FINANCEMENT DU TERRORISME
MONEYVAL
53rd PLENARY MEETING / 53ème RÉUNION PLÉNIÈRE 30 May – 1st June / 30 mai au 1er juin 2017 PALAIS DE L’EUROPE ROOM 1 / SALLE 1
Working Group on Evaluations / Groupe de travail sur les évaluations 29 May / 29 mai 2017 PALAIS DE L’EUROPE ROOM 5 / SALLE 5
LIST OF PARTICIPANTS / LISTE DES PARTICIPANTS
Evaluated States and Jurisdictions / Etats et juridictions evalués
ALBANIA / ALBANIE
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Mr Arlind GJOKUTA financial HEAD OF DELEGATION Director of Albanian Financial Intelligence Unit General Directorate for the Prevention of Money Laundering Ministry of Finance
Mr Agim MUSLIA financial Working Group on Evaluations Director of the Compliance and IT Department General Directorate for the Prevention of Money Laundering Albanian Financial Intelligence Unit, Ministry of Finance
Mr Arben KRAJA law enforcement Prosecutor, Prosecutor’s Office
Mrs Blerina BAJOLLARI law enforcement Specialist in Money Laundering Section Directorate of State Police
Ms Gloria ÇARKAXHIU law enforcement General Directorate of Codification, Ministry of Justice of Albania
Mrs Violanda THEODHORI financial Director of Legal Issues Department Financial Supervising Authority,
Mrs Mirjana GOXHARAJ financial Head of Compliance and Reputational Risk Office Bank of Albania
ANDORRA / ANDORRE
Mr Carles FIÑANA PIFARRÉ financial HEAD OF DELEGATION Chef de la CRF (Centre du Renseignement Financier) Directeur de l’Unité d’Intelligence Financière, Ministère de la Présidence,
Ms Nuria PALOU legal/financial Working Group on Evaluations Supervision Department Financial Intelligence Unit Principality of Andorra – UFIAND
Mr Gérard PRAST legal/financial Working Group on Evaluations (observer) Supervision Department Financial Intelligence Unit Principality of Andorra – UFIAND
ARMENIA / ARMENIE
Ms Tatevik NERKARARYAN financial/legal ACTING HEAD OF DELEGATION Head of the Legal Compliance Department, Financial Monitoring Center, Central Bank of Armenia
Ms Ani GOYUNYAN financial/legal
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Working Group on Evaluations Specialist, International Relations Division, Financial Monitoring Center Central Bank of Armenia,
Mr Edgar ARSENYAN law enforcement Prosecutor
AZERBAIJAN / AZERBAÏDJAN
Mr Anar SALMANOV financial Director of Financial Monitoring Service Financial Markets Supervisory Authority
Mr Azar ABBASOV legal Working Group on Evaluations Head of Legal Department Financial Monitoring Service, Financial Markets Supervisory Authority
Mr Samad SAMADOV law enforcement State Security Service of Azerbaijan Department of Anti-money laundering and counter terrorist financing
BOSNIA AND HERZEGOVINA / BOSNIE-HERZÉGOVINE
Ms Damirka MIOČ HEAD OF DELEGATION Working Group on Evaluations Chief of the Analytical Section, Financial Intelligence Department State Investigation and Protection Agency (SIPA), Ministry of Security
Mr Rajko ĆUK Head of Department for Financial Investigation and Money Laundering, Criminal Police Ministry of Interior of Republic Srpska
Mr Edin JAHIĆ Chief of the Section for Combating Organized Crime and Corruption Ministry of Security of Bosnia and Herzegovina
BULGARIA / BULGARIE
Mr Evgeni EVGENIEV law enforcement HEAD OF DELEGATION Working Group on Evaluations Director, International Information Exchange Sector, Financial Intelligence Unit, State Agency for National Security (FID-SANS)
Mr Nedko KRUMOV financial LAW ENFORCEMENT EVALUATOR FOR SLOVENIA Working Group on Evaluations Head of International Cooperation and Analytical Department - FID-SANS
Ms Cvetelina Ananieva STOYANOVA legal Head of Preliminary Analysis, Financial Intelligence Directorate State Agency for National Security
Ms Tea Vassileva PENEVA legal Senior expert of International Legal Cooperation and European Affairs Directorate
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Ministry of Justice
Mr Trifon TRIFONOV Secretary General Commission on Forfeiture of Illegally Acquired Assets
Mrs Valentina STEFANOVA Director of Restructuring of Investment Intermediaries Directorate Financial Supervision Commission
Mrs Larisa ANGELOVA Inspector in bank supervision Special Supervision Directorate Bulgarian National Bank
CROATIA / CROATIE
Mr Tomislav SERTIĆ legal LEGAL EVALUATOR FOR SLOVENIA Working Group on Evaluations Head of Department for Inter-Institutional and International Cooperation Service for Prevention and Supervision of Reporting Entities Anti-Money Laundering Office, Ministry of Finance
Mrs Marcela KIR financial Working Group on Evaluations Chief Advisor, Payment Operations Area, Croatian National Bank,
Mrs Željka KLJAKOVIĆ GAŠPIĆ Service for Economic Crime and Corruption, Police National Office for Supression of Corruption and Organized Crime Ministry of the Interior
Mrs Sani LJUBIČIĆ apologized County State Attorney, County Attorney’s Office Zagreb
CYPRUS / CHYPRE
Mrs Eva ROSSIDOU-PAPAKYRIACOU legal HEAD OF DELEGATION Attorney MOKAS – FIU, Law Office of the Republic
Mr Marios NEOPTOLEMOU financial Senior Officer, Central Bank of Cyprus
Mr Panayiotis KOUNTOURESHIS law enforcement MOKAS FIU
CZECH REPUBLIC / RÉPUBLIQUE TCHÈQUE
Ms Jana RUŽAROVSKÁ law enforcement HEAD OF DELEGATION Working Group on Evaluations International and Legal department Financial Analytical Office, Ministry of Finance
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Mr René KURKA financial Director of Management of Sanctions Department, Czech National Bank
Ms Lenka HABRNÁLOVÁ legal Director, International and European Union Department, Ministry of Justice
ESTONIA / ESTONIE
Ms Ülle EELMAA financial HEAD OF DELEGATION Working Group on Evaluations Lawyer, Entrepreneurship and Accounting Policy Department Ministry of Finance
Mr Madis REIMAND law enforcement Police Lieutenant Colonel, Head of Financial Intelligence Unit Estonian Police and Border Guard Board
FRANCE
M. Thibault HENNION CHEF DE DELEGATION Adjoint au chef du bureau Multicom 3 : lutte contre le blanchiment et les juridictions non coopératives - Bureau de la lutte contre criminalité financière et des sanctions internationales Direction générale du Trésor, Ministère des Finances et des Comptes publics Ministère de l’Economie, de l’Industrie et du Numérique
M. François MAGNAUD Chargé de mission, Policy Officer SCN TRACFIN
M. Franck OEHLERT legal Working Group on Evaluations Juriste au Service du droit de la lutte anti-blanchiment et du contrôle interne Secrétariat Général de l’Autorité de contrôle prudentiel et de résolution
M. Arnaud BALESTE Head of CFT Division TRACFIN
M. Xavier BAYLON General Directorate Internal Security
GEORGIA / GEORGIE
Mr Valerian KHASASHVILI financial Financial Monitoring Service of Georgia
Mr Malkhaz NARINDOSHVILI financial FINANCIAL EVALUATOR FOR SLOVENIA Working Group on Evaluations Director of Legal, Methodology and International Relations Department Financial Monitoring Service of Georgia
Ms Tamta KLIBADZE Working Group on Evaluations
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Financial Monitoring Service of Georgia
HOLY SEE / SAINT SIEGE
Mgr Paolo RUDELLI HEAD OF DELEGATION Permanent Observer of the Holy See to the Council of Europe
Dr René BRÜLHART Working Group on Evaluations President of Financial Intelligence Authority
Dr Tommaso DI RUZZA Director of Financial Intelligence Authority
Pr Roberto ZANNOTTI Assistant Promotor of Justice Tribunal of the Vatican City State
Mgr John Baptist ITARUMA Secretary, Permanent Observer Mission of the Holy See to the Council of Europe
Rev. Carlos Fernando DIAZ PANIAGUA Official, Secretariat of State, Section of the Holy See’s Relations with States
Major Davide COLLELA Economic and Financial Police, Vatican Police Force
Dr Federico ANTELLINI RUSSO Office of Supervision and Regulation, Financial Information Authority
HUNGARY / HONGRIE
Mrs Zsófia PAPP legal HEAD OF DELEGATION Working Group on Evaluations Senior Expert, Department for International Finance, Ministry for National Economy
Mr Balázs GARAMVÖLGYI Public Prosecutor, Deputy Head of Department for Priority, Corruption and Organized Crime Cases Office of the Prosecutor General of Hungary
Mr Gábor SIMONKA Head of the Hungarian Financial Intelligence Unit National Tax and Customs Administration, Central Office
Mr Bertalan VAJDA Head of Unit, Anti-Money Laundering Supervision Unit Market Monitoring and Anti-Money Laundering Department Central Bank of Hungary
ISRAEL / ISRAËL
Ms Lynn LERER legal
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Working Group on Evaluations Adv., Assistant to the Legal Counsel Israel Money Laundering and Terror Financing Prohibition Authority
Mr Elhanan HARMOR financial FINANCIAL EVATUATOR FOR SLOVENIA Working Group on Evaluations Manager of Licensees Supervision Unit Investment Department, Israel Securities Authority
ITALY / ITALIE
Ms Maria Rosaria PETTINARI Senior Officer Prevention of Use of the Financial System for Illegal Purposes, Office I Treasury Department, Directorate V, Ministry of Economy and Finance
Mrs Federica LELLI Central Bank of Italy
Mr Italo BORELLO Italian Financial Intelligence Unit
Mr Fabio TERAMO Working Group on Evaluations Treasury Department, Directorate V, Ministry of Economy and Finance
LATVIA / LETTONIE
Mr Viesturs BURKÃNS law enforcement HEAD OF DELEGATION Working Group on Evaluations Head of the Office for Prevention of Laundering of Proceeds Derived from Criminal Activity Prosecutor’s Office of Latvia Republic
Ms Indra GRATKOVSKA Head of the Criminal Justice Department under the Ministry of Justice
Mr Kristaps MARKOVSKIS legal Legal Advisor of Supervision Department Financial and Capital Market Commission Ms Inga FORDA Head of International Financial Markets Policy Division Financial Markets Policy Department of Ministry of Finance
Ms Līga KĻAVIŅA Deputy State Secretary on Financial Matters Ministry of Finance
LIECHTENSTEIN
Mr Daniel THELESKLAF CHAIRMAN OF MONEYVAL / PRESIDENT DE MONEYVAL HEAD OF DELEGATION Working Group on Evaluations Director, Financial Intelligence Unit
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Mr Amar SALIHODZIC law enforcement Working Group on Evaluations International Affairs, Financial Intelligence Unit
Ms Bianca HENNIG financial Working Group on Evaluations (Observer) Executive Office, Legal and International Affairs FMA Financial Market Authority Liechtenstein
Mr Werner MEYER Executive Office, Member of the Executive Board FMA Financial Market Authority Liechtenstein
LITHUANIA / LITUANIE
Mr Vilius PECKAITIS law enforcement HEAD OF DELEGATİON Working Group on Evaluations Head of Compliance Division, Money Laundering Prevention Board Financial Crime Investigation Service under the Ministry of Interior (Lithuania FIU)
Ms Indrė BALČIŪNIENĖ legal Chief Specialist of Legal Cooperation Division International Law Department, Ministry of Justice
Ms Kotryna FILIPAVIČIŪTĖ financial Chief Specialist, Operational Risk Division, Prudential Supervision Department, Supervision Service, Bank of Lithuania
Ms Auksė TRAPNAUSKAITĖ financial Senior Specialist Operational Risk Division, Prudential Supervision Department Supervision Service, Bank of Lithuania.
MALTA / MALTE
Dr Giannella BUSUTTIL legal Lawyer, Office of the Attorney General
Dr Jonathan PHYALL Senior Legal Officer Financial Intelligence Analysis Unit
Mr Raymond AQUILINA law enforcement Senior Police Inspector, Malta Police Force Anti-Money Laundering Unit, Malta Police General Headquarters
MONACO
Mme Marie-Pascale BOISSON apologized CHEF DE DELEGATION Directeur, Service d’Information et de Contrôle sur les Circuits Financiers (SICCFIN) Ministère d’Etat
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Mlle Jennifer PALPACUER legal Chef de Section, Service d’Information et de Contrôle sur les Circuits Financiers (SICCFIN)
M. Romain BUGNICOURT Working Group on Evaluations Chef de Section, Service d’Information et de Contrôle sur les Circuits Financiers (SICCFIN)
MONTENEGRO
Mr Vesko LEKIĆ apologized HEAD OF DELEGATION Director, Administration for the Prevention of Money Laundering and Terrorist Financing
Mr Drazen BURIĆ law enforcement State Prosecutor, Supreme State Prosecutor’s Office
Ms Merima BAKOVIĆ legal Head of the Directorate for Criminal Legislation, Ministry of Justice
Ms Helga DAKIĆ Senior Advisor, Administration for the Prevention of Money Laundering and Terrorist Financing
Ms Ana BOŠKOVIĆ Working Group on Evaluations State Prosecutor, Basic State Prosecutor’s Office
Mrs Hedija REDZEPAGIĆ Head of Compliance Department Central Bank of Montenegro
Mr Mladen DRAGAŠEVIĆ Director, Directorate for Council of Europe and Organization for Security and Co-operation in Europe, General Directorate for Multilateral Affairs, Ministry of Foreign Affairs
POLAND / POLOGNE
Mrs Elzbieta FRANKOW-JASKIEWICZ law enforcement HEAD OF DELEGATION Department of Financial Information, Ministry of Finance
Mr Radosław OBCZYŃSKI financial Working Group on Evaluations Financial Supervision Authority
Mr Jacek LAZAROWICZ legal State Prosecutor’s Office
Mr Rafal KIERZYNKA Ministry of Justice of Poland
REPUBLIC OF MOLDOVA / REPUBLIQUE DE MOLDOVA
Mr Adrian CORCIMARI law enforcement HEAD OF DELEGATION Working Group on Evaluations Deputy Head, Office for Prevention and fight against money laundering
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Mr Andrei BURCIU financial National Bank
Mr Eduard VARZAR legal Deputy Prosecutor, Head of Anticorruption Prosecutor Office
Ms Zinaida CARP legal Ministry of Justice
ROMANIA / ROUMANIE
Mrs Elena HACH legal ACTING HEAD OF DELEGATION Prosecutor, Representative of the General Prosecutor’s Office attached by the High Court of Cassation and Justice
Mrs Steluta Claudia ONCICA Director, Inter-institutional and International Relations Directorate National Office for Prevention and Control of Money Laundering – FIU Romania
Mr Sorin SORESCU financial Working Group on Evaluations General Inspector Supervision Directorate, National Bank of Romania
Mrs Daciana DUMITRU Director, Analysis and Processing of Information Directorate National Office for Prevention and Control of Money Laundering – FIU Romania
Mrs Emilia DIMACHE legal Head of Legal Department. National Office for Prevention and Control of Money Laundering – FIU Romania
Mr Vlase DANIEL Head of Analysis Group, Romanian Intelligence Service
Mrs Dorina RADU financial Principal Inspector, National Agency for Fiscal Administration
Mr Sorin TANASE apologized Legal adviser, Directorate for Crime Prevention, Ministry of Justice, BUCHAREST, Romania
RUSSIAN FEDERATION / FÉDÉRATION DE RUSSIE
Mr Alexey PETRENKO HEAD OF DELEGATION Head of Department, Rosfinmonitoring
Ms Natalia LUKIANOVA Rosfinmonitoring
Mr Evgeny SHEVLYAKOV Rosfinmonitoring
Mr Miroslav KONDRITSKIY Senior Expert, CFT Department Rosfinmonitoring
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Mrs Alessandra SLOBODOVA Head of Division, Bank of Russia
Mr Ivan MEDVEDEV Ministry of Foreigh Affairs
Mr Sergey POTISHKO Ministry of Internal Affairs
Ms Yulia LAFITSKAYA LEGAL EVALUATOR FOR SLOVENIA Working Group on Evaluations Head of Division, Rosfinmonitoring
Ms Elizaveta CHURILINA Working Group on Evaluations Rosfinmonitoring
Ms Alexandra KHLEBNOVA Working Group on Evaluations (Observer) Senior Expert, Rosfinmonitoring
Mr Kirill CHERKALIN Federal Security Service
SAN MARINO / SAINT-MARIN
Mr Nicola MUCCIOLI financial HEAD OF DELEGATION Co-chair of the Working Group on Evaluations Vice – Director of the Financial Intelligence Agency (Sector: Financial Intelligence Unit)
Mr Alberto BURIANI legal Law Commissioner of the Single Court (Sector: Judicial Authority)
Mrs Giorgia UGOLINI Procuratore del Fisco (Sector: Judicial Authority)
SERBIA / SERBIE apologized Mr Željko RADOVANOVIĆ HEAD OF DELEGATION Director of the Administration for the Prevention of Money Laundering Head of Serbian FIU, Ministry of Finance
SLOVAK REPUBLIC / REPUBLIQUE SLOVAQUE
Mr Ivo HRÁDEK law enforcement HEAD OF DELEGATION Senior police officer of International Cooperation Department Financial Intelligence Unit of the Slovak Republic, National Criminal Agency
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Mrs Mariana BUZNOVÁ financial National Bank of Slovak Republic
Mr Daniel LESKOVSKÝ financial Working Group on Evaluations National Bank of Slovak Republic
Mrs Lucia CIRAKOVA financial Ministry of Finance of the Slovak Republic
Mrs Lucia KOPIAROVÁ financial Ministry of Finance of the Slovak Republic
Mr Roman TUROK-HETEŠ financial Ministry of Finance of the Slovak Republic
Mr Martin PETER financial Ministry of Finance of the Slovak Republic
Mr Ladislav MAJERNÍK legal General Prosecution of the Slovak Republic
Mr Roman KRIŠTOFÍK legal Ministry of Foreign and European Affairs of the Slovak Republic
Mr Ján KRÁLIK legal Ministry of Justice of the Slovak Republic
Mrs Zuzana HOZÁKOVÁ law enforcement FIU Slovak Republic
Mr Tomáš GRŰNWALD Deputy to the Permanent Representative Permanent Representation of the Slovak Republic to the Council of Europe
SLOVENIA / SLOVÉNIE
- Ms Maja CVETKOVSKI law enforcement - HEAD OF DELEGATION Working Group on Evaluations - Head of International Cooperation Service - Office for Money Laundering Prevention, Ministry of Finance of the Republic of Slovenia
Mr Darko MUŽENIČ legal Working Group on Evaluations Director, Office for Money Laundering Prevention
Mr Boštjan ŠKRLEC legal Working Group on Evaluations General Director Office of State Prosecutor General
Mrs Petra ŠUBERNIK legal Working Group on Evaluations Office of State Prosecutor General
Mr Bojan GERŠAK law enforcement Working Group on Evaluations
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Senior Specialist Criminal Police Inspector General Police Directorate, Economic Crime Division
Mr Robert ZLOBKO law enforcement Working Group on Evaluations Police, Department for Terrorism
Mrs Jelena MILOŠEVIĆ financial Working Group on Evaluations Bank of Slovenia
Mrs Andreja LANG legal Working Group on Evaluations Ministry of Justice
Mrs Branka GLOJNARIČ legal Working Group on Evaluations Head of Department for Prevention and Supervision, Office for Money Laundering Prevention
Mr Leo PONGRAČIČ law enforcement Working Group on Evaluations Head of Department for Suspicious Transactions Office for Money Laundering Prevention
“THE FORMER YUGOSLAV REPUBLIC OF MACEDONIA” / “L’EX-RÉPUBLIQUE YOUGOSLAVE DE MACÉDOINE”
Mr Toni JANKOSKI Working Group on Evaluations Advisor to the Director, Bureau for Public Security Ministry of the Interior
Mr Vladimir MILOSESKI Public Prosecutor, Office for organised crime and corruption
Ms Iskra DAMCHEVSKA Advisor, Department for international cooperation, Sector for Regulation and System Development, Ministry of Finance, Financial Intelligence Office
Ms Marija ANGELOVSKA STOJANOVSKA Head of Sector for Supervision, regulation and international cooperation Financial Intelligence Office
Ms Aneta GJORCHESKA Head of Department for terrorism financing, Financial Intelligence Office
UKRAINE
Mr Igor GAIEVSKYI legal HEAD OF DELEGATION Working Group on Evaluations Head of Department for Coordination of Financial Monitoring, Legal Department, The State Financial Monitoring Service of Ukraine
Mr Ihor BEREZA Head of Financial Monitoring Department, National Bank of Ukraine KYIV, Ukraine
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Mr Vitalii BEREHIVSKYI Head of International Cooperation with Financial Intelligence Units Department for Financial Investigations The State Financial Monitoring Service of Ukraine
UNITED KINGDOM CROWN DEPENDENCIES / DEPENDANCES DE LA COURONNE BRITANNIQUE
GUERNSEY CROWN DEPENDENCY OF THE UNITED KINGDOM / GUERNESEY DEPENDANCE DE LA COURONNE BRITANNIQUE
Mrs Catherine SWAN legal - HEAD OF DELEGATION Working Group on Evaluations Crown Advocate, Legislative Counsel, Law Officers of the Crown, St. James Chambers,
Mr Richard WALKER financial Working Group on Evaluations (Observer) Director of Financial Crime Policy and International Regulatory Advisor Policy Council of the States of Guernsey
JERSEY CROWN DEPENDENCY OF THE UNITED KINGDOM / JERSEY DEPENDANCE DE LA COURONNE BRITANNIQUE
Mr John HARRIS HEAD OF DELEGATION Jersey Financial Services Commission
Mr Hamish ARMSTRONG financial Working Group on Evaluations Senior Manager, Financial Crime Policy, Office of the Director General Jersey Financial Services Commission
ISLE OF MAN CROWN DEPENDENCY OF THE UNITED KINGDOM / ILE DE MAN DEPENDANCE DE LA COURONNE BRITANNIQUE
Mr Paul HECKLES HEAD OF DELEGATION Working Group on Evaluations AML/CFT Advisor AML/CFT Policy Office, Cabinet Office, Government Office
Ms Karen RAMSAY Head of AML/CFT Policy Office Cabinet Office, DOUGLAS, Isle of Man
Ms Lyndsey BERMINGHAM Head of Financial Intelligence Unit DOUGLAS, Isle of Man
UNITED KINGDOM OVERSEAS TERRITORY OF GIBRALTAR apologized Mr David PARODY
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Finance Centre Director, Gibraltar Finance, National Co-ordinator AML/CFT, HM Government of Gibraltar
Council of Europe Observers / Etats observateurs auprès du Conseil de l’Europe
UNITED STATES OF AMERICA / ETATS-UNIS D’AMERIQUE
Mrs Anna MORRIS Working Group on Evaluations Senior Policy Advisor for Europe Terrorist Financing and Financial Crimes Office, US Department of the Treasury
Mrs Kelly HELHOWSKI Working Group on Evaluations Office of Counterterrorism Finance and Designations Bureau of Counterterrorism, U.S. Department of State
MEXICO
Mr Santiago OÑATE LABORDE Working Group on Evaluations Permanent Observer, Permanent Mission of Mexico to the Council of Europe
Mr José Humberto LÓPEZ-PORTILLO SÁNCHEZ Working Group on Evaluations Attaché for Legal Affairs, Legal Office of the Attorney General of Mexico (PGR) in Europe
GERMANY / ALLEMAGNE Other members of the FATF / Autres membres du GAFI
GERMANY / ALLEMAGNE
Mr Thomas MESSING Working Group on Evaluations Federal Financial Supervisory Authority (BaFin), Anti-Money-Laundering Department, Section GW 1 International, legal and policy issues
Ms Tatjana LEONHARDT Federal Financial Supervisory Authority Anti-Money Laundering Department International, legal and policy issues
KINGDOM OF THE NETHERLANDS / ROYAUME DES PAYS-BAS
Mr Willem HUISMAN Prof. Maria SLOTBOOM Department of Criminal Law and Criminology VU University of Amsterdam
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PORTUGAL
Mr Gil GALVAO HEAD OF DELEGATION Working Group on Evaluations Banco de Portugal
UNITED KINGDOM / ROYAUME UNI
Mrs Colette LANCASTER HEAD OF DELEGATION Working Group on Evaluations Policy Advisor Sanctions and Illicit Finance, International and EU Group HM Treasury
Council of Europe bodies and mechanisms /
Organes et mécanismes suivants du Conseil de l’Europe
COUNCIL OF EUROPE DEVELOPMENT BANK / BANQUE DE DEVELOPPEMENT DU CONSEIL DE L’EUROPE Apologized
EUROPEAN COURT OF HUMAN RIGHTS COUR EUROPEENNE DES DROITS DE L’HOMME
PARLIAMENTARY ASSEMBLY OF THE COUNCIL OF EUROPE (PACE) / ASSEMBLEE PARLEMENTAIRE DU CONSEIL DE L’EUROPE (APCE)
CONFERENCE OF THE PARTİES TO THE CONVENTİON ON LAUNDERİNG, SEARCH, SEİZURE AND CONFİSCATİON OF THE PROCEEDS FROM CRİME AND ON THE FİNANCİNG OF TERRORİSM (CETS NO. 198) / CONFÉRENCE DES PARTİES À LA CONVENTİON RELATİVE AU BLANCHİMENT, AU DÉPİSTAGE, À LA SAİSİE ET À LA CONFİSCATİON DES PRODUİTS DU CRİME ET AU FİNANCEMENT DU TERRORİSME (STCE N° 198)
EUROPEAN COMMITTEE ON CRIME PROBLEMS (CDPC) / COMITE EUROPEEN POUR LES PROBLEMES CRIMINELS (CDPC)
Mr Carlo CHIAROMONTE Secretary to CODEXTER and Head of the Criminal Law Division Action against Crime Department, Council of Europe [email protected]
COUNCIL OF EUROPE DGII – Trafficking in Human beings (GRETA) / CONSEIL DE L’EUROPE DGII – Lutte contre la traite des êtres humains (GRETA)
Mrs Petya NESTOROVA Head of Division and Executive Secretary of the Council of Europe Convention on Action against Trafficking in Human beings
Mr Fatih SUSUZ Administrator [email protected]
COUNCIL OF EUROPE DGII – Unit for Sport Conventions / CONSEIL DE L’EUROPE DGII – Unité des Conventions du Sport
Mr Mikhaël de THYSE Administrator [email protected]
Mrs Cassandra FERNANDES Administrator [email protected]
International organisations and bodies / Organisations et organismes internationaux
EUROPEAN COMMISSION / COMMISSION EUROPEENNE
Mr David SCHWANDER Working Group on Evaluations Policy officer, Anti-Money Laundering and Countering Terrorist Financing, European Commission Directorate-General for Justice and Consumers, Task Force Financial Crime
FINANCIAL ACTION TASK FORCE (FATF) / GROUPE D’ACTION FINANCIÈRE (GAFI)
Ms Shana KRISHNAN Working Group on Evaluations Policy Analyst, Anti-Money Laundering – Counter-Financing of Terrorism Financial Action Task Force – FATF
M. Pierre BARDIN Working Group on Evaluations Policy Analyst, Anti-Money Laundering – Counter-Financing of Terrorism Financial Action Task Force – FATF
INTERNATIONAL MONETARY FUND (IMF) FONDS MONÉTAIRE INTERNATIONAL (FMI)
UNITED NATIONS / NATIONS UNIES
UNODC
Mr Yevheniy UMANETS Working Group on Evaluations UNODC GPML Programme Officer, Global Programme against Money Laundering,
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Proceeds of Crime and the Financing of Terrorism (GPML) Implementation Support Section, Organized Crime and Illicit Trafficking Branch Division for Treaty Affairs United Nations Office on Drugs and Crime (UNODC)
Mr Klaudijo STROLIGO Working Group on Evaluations United Nations Office on Drugs and Crime (UNODC)
WORLD BANK / BANQUE MONDIALE
Mr Theodore C. KOUTS Working Group on Evaluations Financial Market Integrity World Bank Group
Ms Laura POP apologized Financial Sector Specialist World Bank Group
Mr Nigel Marc BARTLETT apologized Financial Sector Specialist World Bank Group
EUROPEAN BANK FOR RECONSTRUCTİON AND DEVELOPMENT (EBRD) BANQUE EUROPEENNE POUR LA RECONSTRUCTION ET LE DEVELOPPEMENT (BERD)
Ms Allison SMITH Working Group on Evaluations Principal, Project Integrity, Office of the Chief Compliance Officer, Integrity Risk and Compliance, European Bank for Reconstruction and Development
GIFCS – GROUP OF INTERNATIONAL FINANCE CENTRE SUPERVISORS GS CFI - GROUPE DE SUPERVISEURS DE CENTRES FINANCIERS INTERNATIONAUX
Mrs Fiona CROCKER Working Group on Evaluations Guernsey Financial Services Commission Group of International Finance Centre Supervisors
EGMONT GROUP of FINANCIAL INTELLIGENCE UNITS / GROUPE EGMONT DES CELLULES DE RENSEIGNEMENTS FINANCIERS ORGANISATION FOR SECURITY AND CO-OPERATION IN EUROPE (OSCE) / ORGANISATION POUR LA SECURITE ET LA COOPERATION EN EUROPE (OSCE)
EURASIAN GROUP ON COMBATING MONEY LAUNDERING AND FINANCING OF TERRORISM (EAG) / GROUPE EURASIE SUR LA LUTTE CONTRE LE BLANCHIMENT ET LE FINANCEMENT DU TERRORISME (EAG)
Mr Vladimir NECHAEV Working Group on Evaluations EAG Executive Secretary
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Scientific Experts / Experts Scientifiques
Professor William C. GILMORE Co-Chair of the Working Group on Evaluations Professor of International Criminal Law, Faculty of Law, University of Edinburgh, Old College
Mr John RINGGUTH Working Group on Evaluations
Mr Philipp RÖSER apologized Rewiever, Ad-Hoc Group of Experts Working Group on Evaluations Executive Office, Legal/International Affairs, Financial Market Authority
Mr Andrew STRIJKER Working Group on Evaluations European Commission, Task Force for Greece Cluster Coordinator Anti Money Laundering and Anti-Corruption
Mr Boudewijn VERHELST Working Group on Evaluations Deputy Director CTIF-CFI, Scientific Expert Law Enforcement, Attorney General,
Secretariat of the Council of Europe /
Secrétariat du Conseil de l’Europe MONEYVAL
Mr Jan KLEIJSSEN Director, Information Society and Action against Crime Directorate General of Human Rights and Rule of Law – DGI [email protected]
Mr Ivan KOEDJIKOV Head of Department and Anti-terrorism Co-ordinator, Action against Crime Department Information Society and Action against Crime, Directorate General of Human Rights and Rule of Law – DGI [email protected]
Mr Matthias KLOTH EXECUTIVE SECRETARY TO MONEYVAL / SECRÉTAIRE EXÉCUTIF DE MONEYVAL Administrator, Directorate General of Human Rights and Rule of Law - DGI, Council of Europe, F – 67075 STRASBOURG Cedex Tel. +33 3 90 21 49 84 / Fax +33 3 88 41 30 17 [email protected]
Mr Lado LALICIC, Head of Unit 1 - AML/CFT Monitoring Unit, Typologies & Conference of the Parties to CETS n°198 - MONEYVAL Tel. +33 3 90 21 63 09 [email protected]
Mr Michael STELLINI, Head of Unit 2 - AML/CFT Monitoring and Training Unit - MONEYVAL Tel: +33 3 88 41 33 59, [email protected]
Mr Andrey FROLOV, Administrator, MONEYVAL
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Tel: +33 3 90 21 52 53, [email protected]
Ms Astghik KARAMANUKYAN, Administrator, MONEYVAL Tel: +33 3 90 21 51 06, [email protected]
Mr Andrew LEBRUN, Administrator, MONEYVAL Tel: + 33 3 90 21 62 69; [email protected]
Ms Ani MELKONYAN, Administrator, MONEYVAL Tel: + 33 3 90 21 28 94; [email protected]
Ms Veronika METS, Administrator, MONEYVAL Tel: +33 3 88 41 24.38, [email protected]
Mrs Francesca MONTAGNA, Administrator, MONEYVAL Tel: +33 3 88 41 33 25; [email protected]
Ms Solène PHILIPPE, Administrator, MONEYVAL Tel: + 33 3 90 21 40 14; [email protected]
Ms Anne VAN ES, Programme Assistant, MONEYVAL Tel: +33 3 90 2 43 27, [email protected]
Mr Alexandre DESCHAMP, Programme Assistant, MONEYVAL Tel. +33 3 90 21 55 09, [email protected]
Mr Panagiotis PSYLLOS, Programme Assistant, MONEYVAL Tel: +33 3 90 2 58 41, [email protected]
Mr Hasan DOYDUK, Administrative Assistant Tel: +33 390 21 53 08, [email protected]
Mrs Odile GEBHARTH, Administrative Assistant Tel. +33 3 90 21 40 45, [email protected]
Ms Monica PETROVICI, Communication and web Assistant Tel: +33 3 88 41 24 93, [email protected]
Mrs Danielida WEBER, Administrative Assistant Tel. +33 3 90 21 46 66, [email protected]
Ms Eva KALF, Trainee Tel: +33 3 88 41 29 56, [email protected]
Interpreters / Interprètes
Ms Sally BAILEY-RAVET Ms Julia TANNER Ms Isabelle MARCHINI
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